BFSG: the German Accessibility Act for online shops

The BFSG (Barrierefreiheitsstärkungsgesetz) is Germany's implementation of the European Accessibility Act. Since 28 June 2025 it requires covered consumer services — including online shops — to be accessible and to publish accessibility information under §14. Supervision lies with the MLBF in Magdeburg, and §37 provides for fines of up to €100,000. Micro-enterprises providing services are exempt.

Who the BFSG applies to

The same three questions as the EAA decide it:

1. the service is offered to consumers (B2C);
2. it is a covered service, such as e-commerce, consumer banking, e-books, passenger transport or electronic communications;
3. the provider is not a micro-enterprise (fewer than 10 employees and turnover or balance sheet of no more than €2 million).

Many small German shops are exempt. Check yours with the three-question filter.

What the BFSG requires from a shop

• The website, app and ordering process must be perceivable, operable, understandable and robust for people with disabilities. The technical reference is EN 301 549, whose web chapter follows WCAG — currently V3.2.1 (WCAG 2.1 AA), with V4.1.1 (WCAG 2.2 AA) published in September 2026 and expected to be cited in late 2026.
• §14 and Annex 3 (Anlage 3): the provider must publish information on how the service meets the accessibility requirements, in an accessible form — in the general terms and conditions or in another clearly visible way. In practice many shops publish a separate page called "Barrierefreiheitserklärung".

The accessibility information (§14, Anlage 3)

Following Annex V of the EAA, the information covers, in plain language:

• a general description of the service in accessible formats;
• descriptions and explanations needed to understand how the service works;
• how the service meets the relevant accessibility requirements.

Many shops also add known limitations, a contact for accessibility feedback and the name of the supervisory authority. That is good practice; check the exact list with your lawyer.

The market surveillance authority can check this information. A missing or incorrect statement is itself a breach. Our accessibility statement guide explains structure and common mistakes.

Supervision: the MLBF

The federal states set up a joint authority, the Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF), based in Magdeburg. It started work in September 2025. It can check services, handle complaints from consumers and associations, and order corrections.

Fines under §37

• Up to €100,000 for certain breaches, including providing a service that does not meet the requirements of §14(1).
• Up to €10,000 for missing or incorrect accessibility information.

These are maximum amounts. As of October 2026 we are not aware of confirmed BFSG fines against online shops; the current picture is inspections, complaints and legal disputes.

Warning letters (Abmahnungen)

In Germany, competitors and qualified associations can send formal warning letters (Abmahnungen) when they consider a breach to be unfair competition. Whether and how this applies to BFSG requirements is a legal question for your lawyer, but it is a reason many German shops take the topic seriously regardless of authority inspections.

Practical steps for a German shop

1. Check whether the BFSG applies to you.
2. Scan your main pages and checkout. Our free check is an automated check, not a full audit, and not legal advice.
3. Fix checkout forms, buttons, contrast and keyboard access first — see the WCAG 2.2 checklist.
4. Publish the §14 accessibility information and keep it up to date.
5. Monitor after every theme or plugin update.

Our reports are available in German, with a draft Barrierefreiheitserklärung generated from a questionnaire for review by your lawyer. For the EU background, read the EAA guide.

Sources

• BFSG §14, gesetze-im-internet.de: https://www.gesetze-im-internet.de/bfsg/__14.html
• BFSG §37, gesetze-im-internet.de: https://www.gesetze-im-internet.de/bfsg/__37.html
• Directive (EU) 2019/882, EUR-Lex: https://eur-lex.europa.eu/eli/dir/2019/882/oj

This page is general information, not legal advice.